Document nmV7BG4Em9M4grVwV6zJOQBpG

== AKT 3636957 ==[ RE: PFAS: 3M's environmental stewardship commitment & Request for a meeting ] == Dokument 2 == [ 3M meeting with MSCA on upcoming EU PFAS restriction under REAC ==| 3M meeting R withMGA pcoming PFAS Restriction under REACH ONLINE MEETING 26 April 202 NDA NTRODUCTION TO 3M RESPONSIBLE MANUFACTURING ater and Carbon-reduction goals Upcycling of fluoropolymers USES of PFAS 3M Fluoropolymers ) 3M Specialty Fluids RMOA for PFAS o F M Bt oo G Who We Are & What We Do Applying our science to improve every life Safety & Industrial Accelerating safety and industry performance by serving the industrial, electrical and safety markets. Transportation & Electronics Moving transportation and a connected world forward by serving automotive and electronic OEM customers. Health Care Connecting people, insights, science and technology to make better health possible around the world by serving the health care industry. Consumer Innovating to simplify life and work by serving global consumers. 26A3pMril 2021. All Rights Reserved. 3M Confidential. 3 3M in Europe: 20.000 employees, 40 manufacturing sites & 10 R&D centers On the picture: 3M manufacturing sites Wuppertal Kamen Aycliffe Skelmersdale Amersfoort Hilden Kerkrade Antwerp Bad Essen Gagnef Vstervik Vrnamo Volokolamsk Alabuga Bangor Clitheroe Loughborough Atherstone Gorseinon Bridgend Tilloy Wroclaw (x2) Janinow Rabka Meerbusch Gendorf- Banska Bystricia Villach EMFI - Niedermodern EMFI - Haguenau Rivas Mazeres Seefeld & Landsberg Niederstetten Kempten Grassobbio Marcallo Corlu 26A3pMril 2021. All Rights Reserved. 3M Confidential. La Mure Cerkezkoy 4 Who We Are & What We Do 2 Fluorine materials manufacturing sites in Europe, approx. 1125 employees ZWIJNDRECHT, BELGIUM GENDORF, GERMANY 26A3pMril 2021. All Rights Reserved. 3M Confidential. 5 New Carbon & Water commitments Building on 3M Sustainability Strategic Framework Science for Circular Our water goals will reduce water use by 25% in our facilities (10% by 2022, 20% by 2025 & 25% by 2030), and improve water quality when returned to the environment after use in our manufacturing operations 26A3pMril 2021. All Rights Reserved. 3M Confidential. Science for Climate Our carbon goal will make 3M achieve carbon neutrality in operations by 2050 while aiming for a 50% reduction of carbon emissions by 2030 and 80% by 2040 (note: 2019 is the baseline measure year) Science for Community Our social goals expand opportunities for underrepresented communities to participate and succeed in the future workplace, and make 3M lead in social equity and justice 6 Vision: The Fluorine Cycle Polymer Life Cycle Fluorspar R22 Monomer Perfluorinated Fluoropolymers Polymer Monomer Partially Fluorinated Fluoropolymers Circular technology Can be used for Fluoropolymers Manufacturing waste or post-use industrial material is decomposed back to key raw materials Raw materials can be used to produce new PTFE Pilot scale for perfluorinated Fluoropolymers demonstrated in Gendorf, Germany Reduced Environmental Impact for Perfluoropolymers per 1,000 t TFE produced: ( 5,000 t) Chlorine (10,000 t) CO2 (10,000 t) Acid byproduct ( 2,000 t) Sulfuric acid ( 3,000 t) Gipsum Pilot Plant development was supported by German Federal Ministry for Environment, Nature Conservation and Nuclear Safety 3 Our PFAS-enabled* applications: ~25,000 products. Some examples: Certain medical devices Certain personal protective equipment Energy-efficient window films Renewable energy products (= 3M Wind Blade Protective Coating) Road safety products (= road & pavement markings, reflective traffic signs) Products used in electronics, automotive, aerospace and construction: high-performance adhesives for automotive and aerospace high-performance double sided acrylic foam tapes coated masking paper adhesive transfer tapes enhancing and shielding tapes PFAS-enabled products contain or use PFAS(s) in manufacturing processes, leveraging the chemistry's technical function to perform as intended 26A3pMril 2021. All Rights Reserved. 3M Confidential. 8 Our fluorinated materials: Fluoropolymers Fluoroelastomers Fluorothermoplastics Specialty chemicals (C1/C4 additives) Specialty Fluids 3MTM NovecTM Engineered Fluids 3MTM FluorinertTM Electronic Liquids 3MTM Performance Fluids 3MTM FA-188 Foam Additive 3MTM NovecTM 1230 Fire Protection Fluid 3MTM NovecTM Engineered Fluids 3MTM FluorinertTM Electronic Liquids 3MTM NovecTM 4710 & 5110 Insulating Gases 26A3pMril 2021. All Rights Reserved. 3M Confidential. 9 gA T ? \&0 : ; !/'a }\ P | JD h_m- __..._'x% s R S P NS b Where our fluorinated materials are sold today P > MN Markets = Aerospace = Automotive = Construction = Data Centers = Electronics = Energy = |ndustrial = Medical = Personal Safety = Semiconductor Select Applications = Coatings for aerospace wires that help prevent interference = High temp seals and hoses that help lower emission for autos = High transparency long lived architectural films for stadiums = |mmersion cooling of data center IT hardware = High temperature seals that enable modern electronics production = Conductive coatings that allow zero emission fuel cells = Corrosion resistant lining for industrial pipes = Medical device packaging = Additives for flame retardant computer screens = Heat transfer and testing fluids in semiconductor processing N ' ' b 3M sells broadly into non-consumer markets and supports hundreds of applications with high societal value P \W-- 33MM FFlluuoorrooppoollyymmeerrss 3M Fluoropolymers Non-exhaustive list of uses Corrosion protection & emission reduction in chemical & power plants Fire-safe, durable roof for large events Medical applications Low emission transportation Renewables Enabling semiconductor and pharmaceutical manufacturing Highly stable high molecular weight materials. They have no bio-availability and no mobility in the environment. Indispensable in many applications with high societal value. 3M Fluoropolymers exhibit important and unique performance characteristics and provide important value, often with performance that cannot be achieved with other solutions. 26A3pMril 2021. All Rights Reserved. 3M Confidential. 12 33MM SSppeecciaiallttyy FFlluuiiddss 3M Specialty Fluids Non-exhaustive list of uses Protecting valuable assets from fire Cooling data centers Enabling semiconductor manufacturing Reducing climate impact in the energy sector Addressing thermal management applications in EVs 3M NOVECTM ENGINEERED FLUIDS ARE OFTEN USED IN REPLACEMENT OF OZONE DEPLETING CHEMICALS, CHEMICALS WITH MUCH HIGHER GWP VALUES, HAZARDOUS CHEMICALS OR SUBSTANCES OF VERY HIGH CONCERN 3M Specialty Fluids exhibit important and unique performance characteristics owing to their chemistries and provide important value, often with performance that cannot be achieved with other solutions 26A33pMMril 2021. All Rights Reserved. 3M Confidential. 14 3MTM NovecTM Engineered Fluids: Fluoroketones 3MTM NovecTM 1230 Fire Protection Fluid 3MTM NovecTM 5110 Insulating Gas 3MTM NovecTM 612 Magnesium Protection Fluid 3MTM NovecTM 649 Engineered Fluid Global warming potential (GWP) <1 & non-ozone depleting Novec 1230 is used as a clean agent in fire suppression systems to protect high value assets in applications such as electrical control rooms, underground substations, data centers, telecommunications switch rooms, computer control rooms, airport control towers, clean rooms, computer-controlled manufacturing operations as well as in archives and museums with paper archives, historical documents, price less works of art and antiquities where other fire protection fluids cannot be used. Used in replacement of Halons and HFCs with much h igher GWP. Novec 5110 is used in gas-insulated electrical equipment. Existing installations using gas mixtures with Novec 5110 are demonstr ating the potential to reduce greenhouse gas emissions of up to 99.99% compared to installations using SF 6 Novec 612 is used as an alternative to SF6 as a cover gas to prevent molten magnesium from burning during casting processes. Reductions in GHG emissions of more than 99% can be achieved compared to use of SF6 Novec 649 is an advanced heat transfer fluid with ultralow GWP used in Organic Rankine Cycles (ORC) and electronics cooling a pplications Not considered to be bio-accumulative, not classified for human health hazards in the European Classification, Labeling and Pack aging Regulation, not classified as CMR under CLP Novec 1230 fluid has the highest margin of safety for human occupancy among clean fire suppression agents, including inert gas. Short atmospheric lifetime (1-2 weeks or shorter)1 These fluoroketones degrade through natural processes in the atmosphere and do not redistribute to soil or water to any meaningful degree Expected degradation products of these fluoroketones have been studied. Some sources are listed below. 1) Taniguchi, et.al., J. Phys. Chem. A, 107 (2003), 2674-2679 SOURCES: 1) Taniguchi, et.al., J. Phys. Chem. A, 107 (2003), 2674-2679, 2) Jackson, et al. Environ Sci Tech, 45 (2011), 8030-8036. 26A33pMMril 2021. All Rights Reserved. 3M Confidential. 15 3MTM NovecTM Engineered Fluids: Segregated Hydrofluoroethers 3MTM NovecTM Engineered Fluids 7000, 7100, 7100DL, 7200, 7200DL, 7300, 7500*, 7700, 8200 3MTM NovecTM Engineered Fluids 71DA, 71DE, 71IPA, 72DA, 72DE, 72FL, 73DE 3MTM NovecTM Electronic Coatings 1700, 1702, 1710, 1720, 1908, 2202, 2704, 2708 Lower GWP (57-530) & non-ozone depleting Novec engineered fluids are used in a variety of applications including: Cleaning and vapor degreasing of electronic components, medical device parts such as implants, metal components for automotive or aerospace and precision machine parts; these fluids are often used in replacement of substances of very high concern (SVHC) such as trichloroethylene (TCE), n -propyl bromide (nPB) and high GWP and/or ODP substances such as hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) Solvents in coating formulas and industrial cleaning solutions and for lubricant deposition and silicone deposition in applications in electronics, automotive and medical devices; they are often used in replacement of trichloroethylene (TCE), n-propyl bromide (nPB), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) Heat transfer fluids in semiconductor processing equipment, industrial and medical equipment, freeze drying applications in the manufacture of pharmaceuticals and as testing fluids in semiconductor, electronics and electrical applications Reaction media or inert media and in microfluidics applications for medical testing applications Novec electronic coatings are used for electronic device component protection and for easy -clean and anti-smudge properties on device screens and glass Not considered to be bio-accumulative, not classified for human health hazards in the European Classification, Labeling and Packaging Regulation, not classified as CMR under CLP These segregated hydrofluoroethers degrade over time through natural processes in the atmosphere and do not redistribute to s oil or water to any meaningful degree Expected degradation products of these segregated hydrofluoroethers have been studied. Some sources are listed below. *NOTE: Due to the use of the OECD305 bioconcentration factor (BCF) test as indication of bioaccumulation, 3M expects that Novec 7500 will be labeled as vPvB. 3M does not agree that the results of this test are relevant in the determination of the risk of bioaccumulation for these chemistries. 3M is currently working on potential modifications to the protocol that will be proposed to reduce the uncertainty in the measured result.Reference: Newsted, et. al, Environ. Sci. Technol. 36 (2002), 4761-4769 SOURCES: 1) Ninomiya, et.al., Environ. Sci. Technol 34, (2000), 2973-2978, 2) Wallington, et. al., Journal of Physical Chemistry A, 101 (1997) 8264-8274, 3) Christensen, et. al., Journal of Physical Chemistry A, 102 (1998) 4839-4845, 4) Rodriguez, et.al., Atm Environ, 96 (2014) 145-153, 5) Goto, et. al., Env Sci Tech, 36 (2002) 2395-2402 26A33pMMril 2021. All Rights Reserved. 3M Confidential. 16 3MTM NovecTM Engineered Fluids: Fluoronitrile 3MTM NovecTM 4710 Insulating Gas GWP = 2100 & non-ozone depleting Used in medium-voltage and high voltage gas insulated power generation and distribution equipment including gas insulated switch gear and gas insulated lines Used in gas mixtures with other gases (CO2, CO2/O2) in place of sulfur hexafluoride, SF6, a potent greenhouse gas with GWP of 23,500 Existing installations using gas mixtures with Novec 4710 are demonstrating the potential to r educe GHG emissions by more than 99% compared to installations using SF6 Not considered to be bio-accumulative, classified at the lowest level category for human health hazards in the European Classifi cation, Labeling and Packaging Regulation, not classified as CMR under CLP The fluoronitrile degrades over time through natural processes in the atmosphere and does not redistribute to soil or water to any meaningful degree Expected degradation products of this fluoronitrile have been studied. Sources are listed below. SOURCE: 1) Sulbaek Andersen, et.al., Environ Sci Tech, 51 (2017) 1321-1329. 26A33pMMril 2021. All Rights Reserved. 3M Confidential. 17 Highlighted applications and comparison to alternatives Fire suppression application with 3MTM NovecTM 1230 Fire Protection Fluid Non-PFAS fire protection agents include water, carbon dioxide, dry chemical and inert gases. These non-PFAS fire protection agents can cause corrosion, can damage equipment or valuable artifacts, can be electrically conductive, are slower drying, can leave a residue, may have higher toxicity, may require high operating pressures and may result in higher maintenance costs. Inert gas systems work through a different extinguishing mechanism than HFCs and Novec 1230 fluid by displacing oxygen in an enclosure rather than cooling the fire. As a result, the volume of gas necessary for extinguishment and the pressure at which inert gas systems operate are far greater. As a result, there are extra costs associated with storing the additional volume of gas needed and extra costs required to make the system safe including extra ventilation and extra structural strength to support the weight of the system as well as more expensive testing and checkout costs. Cleaning applications with 3MTM NovecTM Engineered Fluids Non-PFAS cleaning solvents include water, alcohol, n-propyl bromide (nPB), trichloroethylene (TCE) and hydrocarbons. These non-PFAS cleaning solvents and solvents can cause corrosion, have longer drying and processing times and thus use more energy, may be flammable, can have higher levels of toxicity, may have lower material compatibility and/or may be ozone-depleting substances. Unlike aqueous solutions, Novec fluids do not support biological growth and are less equipment and energy intensive and dry quickly with less chance for corrosion. Heat transfer & testing applications with 3MTM NovecTM Engineered Fluids Non-PFAS heat transfer agents include water, ethylene glycol and alcohols, these non-PFAS heat transfer agents can be electrically conductive, can create corrosion, use more energy to reach low temperatures, can be flammable and/or explosive and can have higher levels of toxicity Non-PFAS testing fluids include mineral oil and silicone oils, these other testing fluids may have less efficient heat transfer properties, may be flammable and/or combustible, may have limited operating temperature ranges and can use more energy to reach the required low temperatures and/or high temperatures Insulating gases with 3MTM NovecTM Insulating Gases 4710 & 5110 Non-PFAS electrical insulation includes vacuum, interrupter/air-based technology. However, it unclear if the full voltage range can be covered by this technology. Furthermore, the increased space requirements of this technology when used in high voltage applications results in an overall worse life cycle management assessment compared to equipment using Novec insulating gas mixtures. Novec gases remain in place for the useful life of the equipment. 26A3pMril 2021. All Rights Reserved. 3M Confidential. 18 Sum up 3M's direct and PFAS-enabled products are used in many critical, mainly industrial, applications. Fluoropolymers and 3M Novec Fluids do not present significant health or environmental risks. The absence of these substances' manufacturing or availability in Europe will conflict with the EU's objectives to decarbonize, digitalize and keep people safe. New technologies and processes will reduce further potential releases of any PFAS substance in the environment. REACH restrictions should only be adopted if the authorities demonstrate that the substances present an unacceptable risk to human health or the environment. We believe this is not the case for all PFAS substances and products. Measures based on 'precautionary principle' need to be temporary and proportionate to risks. Those PFAS substances or uses that do not present significant health or environmental risks, and where emissions can be managed, should not fall within the restriction scope. 26A3pMril 2021. All Rights Reserved. 3M Confidential. 19 RMOA for PFAS RMOA should consider exempting both PFAS uses and manufacturing processes where emissions can be managed, controlled or minimized Manufacturing Uses End-of-Life 26A3pMril 2021. All Rights Reserved. 3M Confidential. 20 RMOA for 3M Novec fluids 3M Novec fluids, which are enabling the European Green Deal, should not fall under the scope of the proposed PFAS restriction. 3MTM NovecTM1230 Fire Protection Fluid will be produced at our EMAS-certified site in Belgium (as of 2021). 3M Novec fluids are used in applications of high societal value. They are helping to achieve EU climate objectives and digital agenda. 3M Novec fluids are typically used in closed applications or in applications in which users manage and minimize emissions. In many applications, the fluids are filtered in situ and can be recycled and reused. Any non-PFAS alternative is expected to exhibit inferior performance and added cost. A life cycle assessment (LCA) would need to demonstrate whether use of non-PFAS alternatives would result in a lower potential impact on the environment. 26A3pMril 2021. All Rights Reserved. 3M Confidential. 21 RMOA for Fluoropolymers Fluoropolymers, which are enabling the European Green Deal, should not fall under the scope of the proposed PFAS restriction. 3M Fluoropolymers are produced at an EMAS-certified site in Gendorf, Germany. Fluoropolymers are used in applications of high societal value. They are helping to achieve EU climate objectives and digital agenda. Circular technologies can be used to address manufacturing waste or post-use industrial fluoropolymers by refreshing them back to raw materials. These raw materials can be used to produce new fluoropolymers, reducing the waste production of the site and its environmental impacts. Any non-PFAS alternative is expected to exhibit inferior performance and added cost. A life cycle assessment (LCA) would need to demonstrate whether use of non-PFAS alternatives would result in a lower potential impact on the environment. 26A3pMril 2021. All Rights Reserved. 3M Confidential. 22 "TTHHAANNKK YYOOUU.